Are your engagement letters up to date? Probably not!
No sooner had we given our letters of engagement on the website a refresh for Spring 2021, than the Government passed into law the latest anti-money laundering legislation. The Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021 which is number 3 of 2021 was passed into law on 18 March 2021. It awaits commencement by the Minister.
Once it comes into force it will replace the earlier Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2018. The new title of the Irish anti-money laundering legislation is the ‘Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021’.
The new legislation primarily deals with cryptocurrency, virtual asset providers (VASPs) and estate agents letting property for €10,000 per month or more, high value art dealers and tax advisers (extending the scope of persons who fall within the definition of ‘tax adviser’), among other matters. Previous legislation only dealt with estate agents buying/selling property.
Readers please note that you will need to change the references on your letters of engagement to ‘Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021’ with immediate effect and update AML Manuals and training etc.
A later blog will go into more detail about the changes.
At www.jmcc.ie we have refreshed all of our letters or engagement templates for these references and we keep adding new templates which may be viewed at this link.
